Hi Jennifer,
I work with a large number of physicians who do not participate in any insurance other than Medicare/Medicaid. They (the MDs) feel that since they do not participate, then their services rendered are not subject to the multiple procedure reduction rule often imposed by carriers--regardless of participation status.


For all billing/coding questions I like to consult with an expert.  Today’s answer is provided by Jackie Thelian, CPC, CPC-1, President of Medco Consultants, Inc.

The Multiple Surgery Rule (“MSR”) is a Medicare rule which has been the most commonly adopted rule by all insurance carriers applied when a physician performs separate procedures on the same patient during the same operative session. It is as basic as the global surgical package and applies to all physicians par or non-par.

Medicare policy maintains that these separate procedures are not incidental to the primary procedure and are separately payable. The MSR is applied as follows: 100% of the fee schedule amount is allowed for the procedure with the highest unit value and 50% of the fee schedule amount is allowed for the second and all subsequent procedures.  Add-on Codes listed in Appendix D and Modifier 51 exempt codes listed in Appendix E of the American Medical Association’s Current Procedural Terminology (CPT)® book, are exempt from the Multiple Surgery Processing Rule and are allowed at 100% of the fee schedule allowance.

It is important to note the reimbursement for multiple endoscopies will be reimbursed at the full amount for the highest value endoscopy and then a percentage of the next highest endoscopy based on the relative value units (RVU) of each.

Jackie is the best in the business and the one I recommend you trust to educate your practice about upcoming ICD-10 changes.  Click here to get more information on attending or sending your office manager to attend one of Jackie’s many informative seminars to update your offices coding and billing practices. Jackie’s seminars are MSSNY endorsed and attended by practice managers across the US.

Also, contact Jackie at (718) 217-3802 or at for independent external coding reviews, coding/billing education, compliance and/or coding products.  As you all know from the many compliance topics we discuss, I strongly recommend obtaining a coding review of your documentation on at least an annual basis as part of your Compliance Program. The de minimis cost may just save you an exorbitant amount requested by an audit refund should you not have your documentation reviewed by an expert.


For additional information on this topic, contact Jennifer Kirschenbaum at (516)-747-6700 ext. 302 or at


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